fully recognized in the transactionfrom either a US tax or foreign taxperspective. The Notice highlightsthe following transaction in whichtaxpayers have invoked the Statutory Disposition Rule "to avoid thepurpose of Section 901(m)."EY ...
IRS Guidance on Section 457A Foreign Deferred Compensation RulesBrigen L. Winters
IRS Issues Foreign Tax Credit Guidelines under Section 901(M)Schwarz, Mel
The article reports on a new directive on section 965 foreign earnings repatriation, LMSB-4-0408-021, issued by the U.S. Internal Revenue Service (IRS) on April 21, 2008. The directive follows a series of IRS guidance and directives previously issued on the same topic. The new directive ...
In case of foreign corporation as an acquiring subsidiary the dividends received deductions are inapplicable and there is no special tax rates applied to the parent organization's dividend income. INSET: Where the Deemed Section 351 Transaction Came From.Bogdanski...
IRS Grants 2006 IRC Section 470 Relief; Additional Foreign Currencies Receive Mark-to-Market TreatmentHoward LeventhalDavid Racich, Ernst & Young
IRS Proposes Clarifications to Substantial Risk of Forfeiture Definition in Section 83The Internal Revenue Service has issued proposed regulations that are intended to clarify what constitutes a "substantial risk of forfeiture" for restricted stock and other compensatory restricted property. However, the ...
IRS Issues Proposed Regulations of Code Sec. 1446 withholding Obligations of Partnerships with Foreign Partners, Thecertificate such as a Form W-8BEN or Form W- 81MY containing the information necessary tosupport 754. The Proposed Regulations also provide guidance concern- ing capital losses,suspended...
Parts III and IV examine the tax treat- ment of foreign entertainers and the IRS The performer whohas multiple talents, such as actor/direc- tor or singer/composer, could be Nevertheless, manyforeign entertainers often have artistic ability in other than the performing arts, andFraade, Richard...
Internal Revenue Service has canceled proposed regulations relating to foreign currency gains and losses under the Section 987 of the Internal Revenue Code. The regulations address the income recognition rules applicable to qualified business units (QBU) doing business in a functional currency other than...